Increased Beef Oversight: Needed? or Overkill?

When I strolled into the meat shop last Saturday morning, my E-mail inbox had a surprise waiting for me!  I received notification about yet another meat recall.  But this wasn’t just any old meat recall.  My eyes did a little double take. The recall was for a strain of E. coli known as O26. So, what’s the big deal you say?

Without getting too sciency and geeky, here’s the gist of it… Generally, beef recalls are due to the well publicized virulent (bad … yes, there are “good” ones, too) strain of E. coli known as O157:H7.  For my small business, containing this ubiquitous threat can literally mean the difference of being in business or vaporizing our life’s work.  Yep, it’s the kind of stuff that keeps a gal up at night.  The O157:H7 strain of E. coli is an official adulterant under USDA regulations.  So now, what does that mean?

Well, it basically boils down to the fact that E. coli O157:H7 is highly regulated and strictly enforced with a zero tolerance policy.  This in itself is enough to drive a small (even large!) USDA inspected beef slaughter and fabrication plant mad.  Why?  Folks, there is no sterile raw meat product.  YES, you heard it here.  Not even a small slaughter plant can create a sterile raw meat product.  Try as we may, there are no guarantees.  I know, I know…you heard that grass fed beef or small family farms can’t have E. coli, Salmonella, or whatever bug.  You read somewhere that small slaughterhouses somehow create a magical, mystical safe meat. 
BREAKING NEWS! That just isn’t so.  We are not perfect.  Sterile raw meat is NOT achievable (unless we irradiate it, which we won’t and can’t … it’s a super-pricey investment!).  You heard it here first.

Why not?  Three words: Miniscule Microscopic Nasties (MMN).  I cannot smell, taste or detect MMN’s without a laboratory.  I can use best practices, such as affordable interventions and sanitation to try and control it.  I can sample to ensure those practices are working as best as possible.  I can minimize the risk to the best of my ability – but I cannot eliminate it.

I sample beef carcasses for generic E. coli strains as part of our general food safety routine.  These samples are fairly cost-efficient and can be done in-house.  The idea here is that non-detectable levels of generic will equate to non-detectable levels of O157:H7.  Periodically, I take that a step further.  As a part of HACCP, a plant must prove that their processes are working to control whatver risk has been identified in their HACCP plan.  Beef slaughter’s main risk is O157:H7, which has adulterant (not the Scarlet Letter kind of adultery) status.  That adulterant status is important, so more about this a little later on.  In order to prove that our processes are working I do strain specific sampling.  Meaning I test specifically for the E. coli O157:H7.  This type of sampling is not cost efficient and cannot be done in-house.  The procedure for this requires the live strain of the specific bacterium… which is also a bio-hazard.  This type of testing is best left to an outside laboratory that has the ability to control the hazard.  And it does not come cheap.

What does all this chatter have to do with the E. coli O26 recall?

Recently, there has been a push to legally classify other non-E.coli O157:H7 strains (shiga-toxin producing E. coli, or STEC), E. coli O26 for example, as adulterants.  In short, these strains would be treated the same as O157:H7.  When the webosphere gets riled up and Congress gets involved, my ears begin to perk up (and turn slightly red).  Let’s talk about a few of the more notable entries onto the food safety bandwagon.

In April, 2010 U.S. Senator Gillibrand (D-NY) petitioned the USDA FSIS to declare all STECs to be adulterants.  In May, she introduced new legislation that would add six Non-O157 STECs to the high esteem of adulteration status.  The strains include: O26, O45, O103, O11, O12 and O145.  On July 29th, 2010, Congresswoman DeLauro (D-CT) introduced the E. Coli Traceability and Eradication Act (which is stupid), essentially calling for all STEC (Shinga toxing-producing E. Coli strains) to achieve the same esteem of O157:H7 and eradicate them.  Eradication?   Well, alrighty then.  Wildlife is known to carry the pathogen.  People have died from venison contaminated with STEC.  STEC is in other farm ruminants, too, like goats and sheep – but they get off the hook because they’re consumed in such low numbers.  Also, STEC has been found in chickens, pigs, feral swine (mmmm, rather, GAK!, wild boar), deer, even birds, insects, and squirrels.  Eradication? I think not.

In addition, the bill would require comprehensive testing at multiple stages of beef fabrication multiple times.  As a small slaughterhouse, we provide farmers with services from slaughter to final fabrication.  This particular bill would require us to sample the same beef at multiple stages multiple times at each stage.  If I were to be forced to test for all STECs specifically at multiple stages of processing, what would it cost a farmer to have a beef slaughtered & processed here?  More than you can afford, I can assure you that.

Cue the trial lawyers!  Attorney Bill Marler, the food safety litigation guru extraordinaire, also has a few things to say about non-O157 STECs.  Yes, he’s also petitioned the USDA.  Imagine all those extra cases (business!) he’ll get, as my business continues to face more and more challenges.

While all of this may sound good to someone from the outside looking in, it sends fear to those of us in the trenches.  Maintaining a very small USDA inspected beef slaughter & fabrication plant in this day and age is already extremely complicated, costly, and carries enormous liability.  I am striving to provide you with a safe local source of quality meat of which you and I both can be proud and confident.  I need your help to continue to do that.  We cannot let fear and emotions set our food safety regulations.  The unintended consequences could mean regulating us small local places right out of business.

Folks, we are in this food safety fight together.  There are 100’s of strains of E.coli and likely more that haven’t even been discovered yet.  Yes, some of those strains could make you sick. Eradication is in my opinion impossible.  Yet, the public at large balks (for no good reason) at advance processes like irradiation that can help make the meat supply safer.  There comes a time when common sense needs to take the driver’s seat.  How many legal adulterants should we have?  6?  100?  Where does it end?  When we’re out of business?  Preferably before then.

It is absolutely crucial that you follow some basic safe food handling in your homes.  I will continue to do my part.  Will you continue to do yours?  I’m being fired upon in the trenches.  You think it’s friendly-fire, but it’s not.  I’m asking you to help me stay here.  My family business depends on it.